T.C. Memo. 1996-507
UNITED STATES TAX COURT
SAMUEL C. STONE AND SUSAN C. STONE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26039-93. Filed November 13, 1996.
Samuel C. Stone, pro se.
Ann L. Baker, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
CARLUZZO, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.1 Respondent determined a deficiency in petitioners' 1991
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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